Businesswoman working on project on digital tablet in office

How can organizations turn BEPS Pillar Two compliance into competitive advantage? 


As Pillar Two moves into routine reporting, multinational groups have a narrow window to convert first filing lessons into cleaner data, sharper controls and AI-ready tax processes that create value beyond compliance.


In brief

  • Leveraging experiences from the first BEPS Pillar Two filing process gives multinational groups an opportunity to turn compliance effort into stronger tax data, controls and competitive advantage. 
  • Initial Pillar Two filings highlighted where CbCR,  Safe Harbour modelling and tax accounting rely on manual processes or difficult-to-access data. 
  • Groups should use these insights to standardize tax reporting, strengthen data governance, shape future Safe Harbour strategies and support the broader tax transformation agenda.

The first Base Erosion and Profit Shifting (BEPS) Pillar Two compliance deadlines moved organizations from high-level estimates to detailed execution. Groups prepared qualified Country-by-Country Reports (CbCR), Transitional Safe Harbour assessments, Global Anti-Base Erosion (GloBE) Information Returns and related local filings for the first time. This exercise revealed opportunities to improve data quality and technical application of tax accounting rules.

1. Data

For many organizations, BEPS Pillar Two has proven to be more of a tax compliance exercise than a material tax collection mechanism. One significant outcome, however, is the visibility it provides into the underlying foundations — showing where tax data is difficult to collect, reconcile, explain and control, and exposing the true state of tax and legal entity data quality, tax accounting readiness and jurisdictional reporting capability. 

 

Has tax data become the foundation of the modern tax function?

One of the clearest lessons from the first BEPS Pillar Two reporting cycle is that tax accounting data quality and process maturity have become critical enablers of tax compliance. BEPS Pillar Two calculations begin with tax accounting data, meaning that weaknesses in tax accounting processes, controls or data governance can directly affect both reporting outcomes and tax compliance efficiency.

 

Organizations with a strong tax accounting foundation typically demonstrate:

  • Stable estimates  Prior-year corrections and return to provision adjustments are limited and estimates are documented and defensible.
  • Visibility over tax balances  The tax bases of assets and liabilities are understood and supported.
  • Finance integration – Tax is embedded within the close and reporting cycle rather than operating as a downstream process.

However, many organizations discovered during the first Pillar Two compliance cycle that underlying data challenges significantly increased the effort required to prepare Qualified CbCR, GloBE Information Return (GIR) and Qualified Domestic Minimum Top-up Tax (QDMTT) submissions. Common themes included:

  • Fragmented data sources, resulting in extensive data collection and reconciliation efforts.
  • Manual workarounds, creating audit trail and consistency risks.
  • A disconnect between local and group-level reporting, making outcomes more difficult to explain and reconcile.
  • Limited visibility into key tax adjustments, including pensions, asymmetric foreign exchange, purchase price accounting and non-covered taxes.

How should organizations respond to tax data issues identified through Pillar Two?

Rather than viewing BEPS Pillar Two data issues as one-off compliance challenges, organizations should convert them into a structured improvement agenda:

  • Log the friction – identify which entities, line items and jurisdictions required disproportionate manual effort.
  •  Trace the root cause – determine whether challenges stem from chart-of-accounts design, local-to-group generally accepted accounting principles (GAAP) bridging, governance gaps or tax accounting process limitations.
  • Prioritize improvements with dual value – focus on changes that strengthen both BEPS Pillar Two compliance and broader tax accounting, tax compliance and stakeholder reporting processes.

Is Qualified CbCR still important?

Qualified CbCR remains critical to the Transitional Safe Harbour. In many organizations, CbCR data was assembled through manual mapping between consolidation systems, local reporting packages and standalone reconciliations.

This approach may have been sufficient for the first filing cycle, but it is difficult to scale in an accelerated reporting environment. Organizations that generate reliable CbCR insights earlier in the reporting cycle gain more time to identify data issues, understand Safe Harbour outcomes and prepare for full GloBE calculations where required.

2. Value beyond tax compliance

As tax functions face increasing pressure to leverage artificial intelligence (AI) while simultaneously preparing for increasing tax transparency and real-time reporting obligations, high-quality trusted data is becoming a critical strategic asset and a foundation for tax transformation.

How can standardized tax data add value after compliance?

Tax data creates value when it helps organizations manage effective tax rate, cash tax, risk and business decisions more effectively. High-quality tax data allows tax teams to identify issues earlier, explain outcomes more clearly and support decisions before they are implemented. The value is not limited to reducing the effective tax rate. It also includes improving cash flow, identifying missed incentives, strengthening operating model effectiveness and supporting transaction planning.

Why are expectations of the tax function changing?

Perhaps the real question is not whether organizations should invest in tax accounting and data, but whether tax teams can meet the growing demands of BEPS Pillar Two, AI, tax transparency and increasing expectations from C-suite stakeholders to operate as strategic business partners without such investment. Organizations that invest now will be better positioned to optimize their tax function – spending less time validating data and more time managing risk, informing business decisions, identifying opportunities and responding to growing stakeholder expectations across the organization.

What should organizations do next?

Summary

Organizations should use the period after the first BEPS Pillar Two filings to improve tax data, automate recurring compliance processes and make deliberate Safe Harbour choices. Addressing underlying weaknesses becomes critical as reporting requirements become more demanding.


FAQs

Related articles

Post Pillar Two: the GloBE compliance lifecycle in Switzerland

Read our insights to navigate the complex GloBE compliance lifecycle in Switzerland with BEPS Pillar Two. Stay ahead with GloBE rules and GloBE Tax.

About this article

Authors

Contributors

Request for proposal (RFP) - exclusively for Switzerland

|

Submit your request now!